Opportunities and Traps in the Tax Treatment of Transaction Costs and Intangible Asset Costs PDF Download
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Author: Andy A. Torosyan
Publisher:
ISBN:
Category :
Languages : en
Pages : 13
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Book Description
Companies buying or selling businesses incur billions of dollars in transaction costs every year. Unlike typical business expenses, there are rules that prevent taxpayers from currently deducting transaction costs and, in some cases, ever deducting these costs. To clarify this area, in 2003 Treasury and the Internal Revenue Service issued final regulations under §263.3 Reg. §1.263(a)-4 and Reg. §1.263(a)-54 provide comprehensive rules about the treatment of costs related to intangible assets, including transaction costs incurred in mergers and acquisitions and certain real estate transactions. The IRS has also issued guidance for success-based fees (or contingent transaction costs) and for milestone payments. However, it appears the safe harbor provisions for success-based fees exclude sellers' costs in asset sales. The phrase ''transaction costs'' includes direct and indirect costs. Specifically, costs incurred in facilitating the acquisition or disposition of a trade or business, a change in capital structure, formation of legal entities, borrowings, and other similar transactions. Costs incurred in other transactions, such as construction of real estate and the purchase of machinery also are subject to capitalization. The focus of this article is transactions described in Reg. §1.263(a)-4 and Reg. §1.263(a)-5 with a focus on opportunities and pitfalls.
Author: Andy A. Torosyan
Publisher:
ISBN:
Category :
Languages : en
Pages : 13
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Book Description
Companies buying or selling businesses incur billions of dollars in transaction costs every year. Unlike typical business expenses, there are rules that prevent taxpayers from currently deducting transaction costs and, in some cases, ever deducting these costs. To clarify this area, in 2003 Treasury and the Internal Revenue Service issued final regulations under §263.3 Reg. §1.263(a)-4 and Reg. §1.263(a)-54 provide comprehensive rules about the treatment of costs related to intangible assets, including transaction costs incurred in mergers and acquisitions and certain real estate transactions. The IRS has also issued guidance for success-based fees (or contingent transaction costs) and for milestone payments. However, it appears the safe harbor provisions for success-based fees exclude sellers' costs in asset sales. The phrase ''transaction costs'' includes direct and indirect costs. Specifically, costs incurred in facilitating the acquisition or disposition of a trade or business, a change in capital structure, formation of legal entities, borrowings, and other similar transactions. Costs incurred in other transactions, such as construction of real estate and the purchase of machinery also are subject to capitalization. The focus of this article is transactions described in Reg. §1.263(a)-4 and Reg. §1.263(a)-5 with a focus on opportunities and pitfalls.
Author: Michelle Markham
Publisher: Kluwer Law International B.V.
ISBN: 9041123687
Category : Law
Languages : en
Pages : 360
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Book Description
Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
Author: Charles H. Gustafson
Publisher: West Academic Publishing
ISBN: 9780314911711
Category : Casebooks
Languages : en
Pages : 0
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Book Description
Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Author: Jonathan Haskel
Publisher: Princeton University Press
ISBN: 0691183295
Category : Business & Economics
Languages : en
Pages : 292
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Book Description
Early in the twenty-first century, a quiet revolution occurred. For the first time, the major developed economies began to invest more in intangible assets, like design, branding, and software, than in tangible assets, like machinery, buildings, and computers. For all sorts of businesses, the ability to deploy assets that one can neither see nor touch is increasingly the main source of long-term success. But this is not just a familiar story of the so-called new economy. Capitalism without Capital shows that the growing importance of intangible assets has also played a role in some of the larger economic changes of the past decade, including the growth in economic inequality and the stagnation of productivity. Jonathan Haskel and Stian Westlake explore the unusual economic characteristics of intangible investment and discuss how an economy rich in intangibles is fundamentally different from one based on tangibles. Capitalism without Capital concludes by outlining how managers, investors, and policymakers can exploit the characteristics of an intangible age to grow their businesses, portfolios, and economies.
Author: Yariv Brauner
Publisher: Edward Elgar Publishing
ISBN: 1788975375
Category : Law
Languages : en
Pages : 416
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Book Description
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Author:
Publisher:
ISBN:
Category : Natural gas
Languages : en
Pages : 162
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Book Description
Systems of accounts applicable to Class A, B, C, and D utilities.
Author: United States. Federal Power Commission
Publisher:
ISBN:
Category : Public utilities
Languages : en
Pages : 151
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Book Description
Author: William D. Popkin
Publisher: Debolsillo
ISBN:
Category : Income tax
Languages : en
Pages : 776
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Book Description
Author: Kimberly K. Merriman
Publisher: Springer
ISBN: 3319589342
Category : Business & Economics
Languages : en
Pages : 104
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Book Description
This book addresses the gap between the espoused importance of organizational human capital and how it is actually reported and assessed. It also discusses the current and potential uses of human capital measurement and a way for HR to position itself among other business functions such as finance, accounting, and operations. Readers will finish with an understanding of approaches for the valuation of a firm’s human capital, practical applications for the economic analysis of human capital, and gaps that are ripe for research and practice to address.
Author:
Publisher:
ISBN:
Category : International business enterprises
Languages : en
Pages : 1448
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Book Description
